OSHA Hopes New Injury Data Collection Rule Will Prevent Future Injuries

OSHA inspector

OSHA has updated their rule related to the collection of injury and illness reporting to improve transparency of workplace hazards to employees and the public. The new rule will require certain employers to electronically submit injury and illness data to OSHA. The goal is to encourage employers to better identify hazards, address safety issues, and prevent future injuries and illnesses. The new electronic reporting requirements will be phased in over two years beginning in January 2017 (OSHA).

The collected data will allow OSHA to create the largest publicly-available data set of workplace injuries and illnesses; this will help researchers advance the study of injury causation and more accurately evaluate effective injury and illness prevention activities.

Applying the concept of behavioral economics, OSHA hopes that, ultimately, more attention to safety will save more workers’ lives. The disclosure of an organization’s injury data will naturally motivate employers to improve workplace safety practices by allowing them to compare themselves to other companies in their specific industry. This will encourage employers to compete for top rankings in worker safety and to innovate new ways to identify and prevent hazards and health risks.

An essential aspect of the rule is anti-retaliation protection for employees. For the data to be accurate, workers must be informed of their right to report work-related injuries or illnesses without fear of retaliation. Employers will now be prohibited from using post-incident drug testing as a form of adverse action against employees who report injuries or illnesses. Employers are encouraged to review and revise drug testing policies to achieve compliance with the new requirements. In order to educate the regulated community, the enforcement of the anti-retaliation provisions have been delayed until Dec. 1, 2016 (U.S. Department of Labor, 10/18/16).


New Recordkeeping Requirement Compliance Schedule:

Employers with 20-249 employees in high hazard industries must electronically submit their OSHA 300A form for the year 2016 by July 1, 2017

Employers with 250 or more employees in industries newly covered by the recordkeeping rule must electronically submit their OSHA 300A form for the year 2016 by July 1, 2017

• These same employers will need to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018

OSHA State Plans must also adopt and enforce these requirements within 6 months.

Succeed Management Solution, LLC offers Incident Track® to assist organizations to efficiently track, report, and analyze incidents, including OSHA-reportable injuries and illnesses and near-misses. This web-based software application will seamlessly export all OSHA-required forms electronically directly to OSHA and provide all of the data required by the new OSHA rules. Incident Track® is part of the Risk Management Center®, a suite of applications that assist organizations with their risk management, workplace safety, employee training, and compliance needs.

Reminder: Post OSHA 300A Summary Form by February 1st

Employers with 11 or more employees (including temporary employees) are required to post the OSHA 300A Summary form in a public area of the workplace from February 1 through April 30, 2016, for the previous year. This form is a representation of the total number of injuries and illnesses recorded for the year, as documented in the OSHA 300 Log. The OSHA 300 Log is an ongoing list of all recordable injuries, illnesses, and fatalities at an organization.

There are exempt industries that are not required to post the OSHA 300A Summary, however since January 1, 2016, OSHA has decreed that additional industries are now required to post this form. These industries include automobile dealers, bakeries, beer, wine, and liquor stores, performing arts companies, special food services, building material and supplies dealers, and more. Even if your organization is exempt, you still have to complete the forms if there has been a fatality, in-person hospitalization, amputation, or if an employee lost an eye due to a work-related incident.

The OSHA 300 forms are requested in any OSHA visit. Citations and fines may result if your organization does not comply. Regardless of OSHA, it is a best practice to keep a record of all injuries, and perform investigations to assess the root causes, at risk behaviors, and other factors that can help organizations prevent injuries.

Please use these links below for more information on the OSHA 300 log process, or to sign up for a free webinar.

View a short introductory video on the OSHA 300 logs
Sign up for a free educational webinar on the OSHA 300 log process
View the pre-recorded educational webinar